Stefano Bognandi and Alfredo Fossati of LED Taxand discuss how case law and mutual agreement procedures (MAPs) are altering the transfer pricing (TP) dispute landscape in Italy.


In recent years, the Italian tax authority (ITA) has increasingly been carrying out inspections to check the consistency of the TP policy applied by multinational enterprises (MNEs), giving rise to a number of tax litigation cases.

Although alternative means of dispute settlement are likely to be predominant, judicial proceedings are still frequently used to settle TP disputes. At the same time, there is a significant increase in the number of cases where unilateral or international proceedings are activated to eliminate double taxation arising from TP claims.

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